privacy policy

Banking Hub Services

Effective Date: [20/09/2025]

Last Updated: [July 2025]

INTRODUCTION

Banking Hub Services (“we,” “us,” “our,” or “the Company”) is committed to protecting the

privacy and personal information of our customers, prospects, and website visitors (“you,”

“your,” or “Data Principal”). This Privacy Policy explains how we collect, use, store, share, and

protect your personal information in accordance with applicable Indian laws, including the Digital

Personal Data Protection Act, 2023 (“DPDP Act”), Information Technology Act, 2000, and

Reserve Bank of India guidelines.

Our Contact Information:

Company Name: Banking Hub Services

Address: Block C-14, Shop No., Cloth Market, Sanjay Place, Agra – 282002, Uttar Pradesh,

India

Website: https://bankinghubservices.com

Email: bankingserviceshub@gmail.com

Phone: (+91) 9758043094

1. SCOPE AND APPLICATION

1.1 Applicability

This Privacy Policy applies to:

All personal information collected through our website, mobile applications, and digital

platforms

Information collected during loan application processes and service delivery

Data obtained through our physical offices and partner banks

Information shared with or obtained from our network of 10 partner banks

All digital and non-digital interactions with Banking Hub Services

 

1.2 Services Covered

This policy covers data processing activities related to:

Business Loan Facilitation: Data collected for business loan applications and processing

Home Loan Assistance: Personal and financial information for home loan services

Personal Loan Processing: Individual financial and personal data for personal loans

Credit Assessment Services: Information used for creditworthiness evaluation

Customer Support and Communication: Data related to service inquiries and support

 

1.3 Legal Basis

We process personal information based on:

Consent: Explicit consent obtained from you for specific processing purposes

Contractual Necessity: Processing required to fulfill loan facilitation services

Legal Obligation: Compliance with RBI guidelines, KYC norms, and other applicable laws

Legitimate Interest: Business operations and fraud prevention (where permitted by law)

 

2. DEFINITIONS

2.1 Key Terms

“Personal Data” means any information relating to an identified or identifiable natural

person

“Sensitive Personal Data” includes financial information, biometric data, health records,

and other sensitive categories as defined under applicable law

“Data Principal” refers to the individual to whom the personal data relates (you)

“Data Fiduciary” refers to Banking Hub Services as the entity determining the purpose and

means of processing

“Data Processor” refers to any entity processing personal data on behalf of Banking Hub

Services

“Partner Banks” refers to the 10 banks and financial institutions with whom we have tie-up

arrangements

“Processing” includes collection, recording, organization, storage, adaptation, retrieval,

consultation, use, disclosure, and erasure of personal data

 

2.2 Categories of Personal Data

Identity Information:

Name, date of birth, gender, nationality

Government-issued identification numbers (Aadhaar, PAN, Passport, Voter ID, Driving

License)

Photographs and biometric information (where legally permitted)

Digital signatures and electronic records

Contact Information:

Residential and business addresses

Mobile numbers and landline numbers

Email addresses and communication preferences

Emergency contact details

Financial Information:

Bank account details and statements

Income and employment information

Credit history and credit scores

Investment and asset details

Tax information and GST details

Loan history and repayment records

Professional Information:

Employment details and employer information

Business registration details

Professional qualifications and certifications

Income sources and financial statements

 

3. INFORMATION COLLECTION

3.1 Information We Collect Directly

During Application Process:

Personal identification and contact details

Financial and employment information

Property details (for secured loans)

Business information (for business loans)

 

References and guarantor information

Purpose of loan and intended use of funds

Through Digital Platforms:

Website usage data and analytics

Device information and IP addresses

Cookies and tracking technologies

Search queries and navigation patterns

Form submissions and document uploads

Communication records and chat logs

During Service Delivery:

Service preferences and customization settings

Feedback and survey responses

Complaint and grievance details

Payment and transaction information

Document verification records

 

3.2 Information from Third Parties

Partner Banks and Financial Institutions:

Credit assessments and loan eligibility information

Risk evaluation reports

Compliance and verification data

Transaction history and banking relationships

Credit Information Companies:

Credit reports from CIBIL, Experian, Equifax, and CRIF High Mark

Credit scores and credit history

Default and delinquency records

Public records and legal proceedings information

Government and Regulatory Databases:

KYC verification through CKYC registry

Aadhaar-based eKYC and verification

Income tax records and GST data

Corporate registry and business verification data

Service Providers and Agents:

 

Data from authorized dealers and agents

Third-party verification services

Background verification agencies

Legal and technical consultants

 

3.3 Automatic Data Collection

Website and Mobile Analytics:

Page views, session duration, and user flow

Device type, browser information, and operating system

Geographic location and time zone

Referral sources and marketing attribution

Error logs and performance metrics

Cookies and Tracking Technologies:

Essential Cookies: Required for website functionality and security

Analytics Cookies: Used to understand user behavior and improve services

Marketing Cookies: For targeted advertising and promotional communications (with

consent)

Social Media Cookies: Integration with social media platforms (with consent)

 

4. PURPOSE AND LEGAL BASIS FOR PROCESSING

4.1 Primary Purposes

Loan Facilitation Services:

Assessing loan eligibility and creditworthiness

Facilitating communication with partner banks

Processing loan applications and documentation

Providing status updates and service notifications

Managing loan lifecycle and customer relationship

Risk Management and Compliance:

Conducting KYC and AML verification

Fraud detection and prevention

Regulatory reporting and compliance

Legal obligation fulfillment

Audit and internal controls

 

Customer Service and Support:

Responding to inquiries and providing assistance

Handling complaints and grievances

Service improvement and quality assurance

Training and development of staff

Customer satisfaction surveys and feedback

 

4.2 Secondary Purposes (With Consent)

Marketing and Business Development:

Promotional communications about relevant financial products

Market research and customer insights

Product development and service enhancement

Cross-selling and up-selling activities

Partnership and referral programs

Analytics and Business Intelligence:

Website and service usage analytics

Performance measurement and optimization

Business reporting and strategic planning

Competitive analysis and market intelligence

Technology improvement and innovation

 

4.3 Legal Basis for Processing

Consent-Based Processing:

Marketing communications and promotional activities

Non-essential cookies and tracking

Data sharing for value-added services

Market research and surveys

Optional service features

Contractual and Legal Processing:

Loan application processing and service delivery

KYC and AML compliance

Regulatory reporting obligations

Legal proceedings and dispute resolution

Fraud prevention and security measures

 

5. DATA SHARING AND DISCLOSURE

5.1 Sharing with Partner Banks

Loan Processing and Approval:

Complete application information and supporting documents

Credit assessment data and risk evaluation

KYC verification results and compliance records

Financial information and employment details

Property valuation and legal verification reports

Purpose and Limitations:

Data shared strictly for loan evaluation and processing

Limited to information necessary for credit decision

Governed by data sharing agreements with partner banks

Regular monitoring and audit of data usage

Compliance with banking regulations and RBI guidelines

 

5.2 Regulatory and Legal Disclosures

Government Authorities:

Reserve Bank of India and other financial regulators

Income Tax Department and GST authorities

Law enforcement agencies (under legal process)

Courts and tribunals (as per legal orders)

Anti-money laundering and counter-terrorism authorities

Credit Information Companies:

Loan application and approval information

Repayment performance and default records

Credit utilization and financial behavior

Identity verification and KYC status

Legal proceedings and recovery actions

 

5.3 Service Providers and Vendors

Technology and IT Services:

Cloud service providers and data hosting companies

Software vendors and system integrators

Cybersecurity and data protection service providers

Website analytics and digital marketing platforms

Customer support and call center services

Professional Services:

Legal advisors and consultants

Auditors and compliance specialists

Risk management and credit assessment agencies

Document verification and background check services

Collection and recovery agents (where applicable)

 

5.4 Data Sharing Safeguards

Contractual Protection:

Data processing agreements with all third parties

Confidentiality and non-disclosure obligations

Security and data protection requirements

Audit rights and compliance monitoring

Data retention and deletion obligations

Technical Safeguards:

Encrypted data transmission and storage

Access controls and user authentication

Activity logging and monitoring

Data masking and pseudonymization

Secure API integration and data exchange

 

6. DATA SECURITY AND PROTECTION

 

6.1 Technical Safeguards

Encryption and Data Protection:

End-to-end encryption for data transmission

AES-256 encryption for data at rest

SSL/TLS certificates for website security

Database encryption and key management

Secure file transfer protocols

Access Controls and Authentication:

Multi-factor authentication for system access

Role-based access control and privilege management

Regular access reviews and user provisioning

Strong password policies and account lockout mechanisms

Biometric authentication where applicable

Network and Infrastructure Security:

Firewall protection and intrusion detection systems

Regular security patches and vulnerability management

Network segregation and traffic monitoring

DDoS protection and load balancing

Secure cloud infrastructure and data centers

 

6.2 Organizational Safeguards

Data Governance and Management:

Data classification and handling procedures

Regular security awareness training for employees

Background verification for staff handling sensitive data

Confidentiality agreements and code of conduct

Incident response and business continuity plans

Quality Assurance and Monitoring:

Regular security audits and penetration testing

Continuous monitoring and threat detection

Data quality checks and validation procedures

Compliance monitoring and reporting

Third-party security assessments

 

6.3 Data Breach Response

Detection and Assessment:

Automated monitoring and alert systems

Rapid incident identification and classification

Impact assessment and risk evaluation

Forensic investigation and evidence preservation

Stakeholder notification and communication

Response and Recovery:

Immediate containment and mitigation measures

System restoration and data recovery procedures

Regulatory notification within 72 hours (as required)

Customer notification and support services

Post-incident review and process improvement

 

7. DATA RETENTION AND DELETION

7.1 Retention Principles

Purpose-Based Retention:

Data retained only as long as necessary for stated purposes

Regular review of retention needs and legal requirements

Automated deletion processes where feasible

Clear retention schedules for different data categories

Documentation of retention decisions and rationale

Legal and Regulatory Requirements:

KYC records: Minimum 5 years after account closure (RBI guidelines)

Loan documentation: 3 years after loan closure or as per banking norms

Transaction records: As per applicable banking regulations

Compliance records: As required by regulatory authorities

Legal proceedings: Until resolution and appeal periods expire

 

7.2 Data Categories and Retention Periods

Customer Application Data:

Approved applications: 7 years from loan closure

Rejected applications: 2 years from rejection date

Incomplete applications: 1 year from last activity

Supporting documents: As per loan documentation requirements

Communication records: 3 years from last interaction

Website and Digital Data:

Website analytics: 26 months (Google Analytics default)

Cookie data: As per cookie settings and consent

Marketing data: Until consent withdrawal or 3 years

Error logs: 1 year for troubleshooting purposes

Security logs: 1 year for audit and compliance

 

7.3 Data Deletion Process

Customer-Initiated Deletion:

Right to erasure upon consent withdrawal (subject to legal obligations)

Secure deletion within 30 days of valid request

Verification of identity before processing deletion requests

Notification to third parties about deletion requirements

Documentation of deletion activities for audit purposes

Automated Deletion:

Scheduled deletion based on retention policies

System-generated deletion logs and confirmations

Regular cleanup of temporary and cached data

Secure overwriting of deleted data

Compliance verification and reporting

 

8. YOUR RIGHTS AS A DATA PRINCIPAL

 

8.1 Right to Information

Transparency and Disclosure:

Right to know what personal data is being processed

Information about purposes and legal basis for processing

Details of data recipients and sharing arrangements

Retention periods and deletion procedures

Contact information for data protection queries

How to Exercise:

Submit written request to our Privacy Officer

Provide identity verification as required

Specify the information you wish to access

Response within 30 days of valid request

No fee for reasonable requests (fees may apply for excessive requests)

 

8.2 Right to Correction and Update

Data Accuracy and Completeness:

Right to correct inaccurate or incomplete personal data

Right to update outdated information

Right to complete missing data elements

Right to challenge data quality and accuracy

Right to documentation of corrections made

Correction Process:

Online account access for self-service updates

Email or written request for complex corrections

Verification of identity and supporting documentation

Notification to relevant third parties about corrections

Confirmation of corrections within 15 days

 

8.3 Right to Erasure (Right to be Forgotten)

Deletion Rights:

Right to request deletion of personal data (subject to legal limitations)

Right to withdraw consent for consent-based processing

Right to object to processing based on legitimate interests

Right to delete data that is no longer necessary

 

Right to delete unlawfully processed data

Limitations and Exceptions:

Legal obligations preventing deletion (KYC, AML, tax records)

Ongoing legal proceedings or disputes

Regulatory requirements and compliance obligations

Fraud prevention and security considerations

Archival and historical record requirements

 

8.4 Right to Data Portability

Data Transfer Rights:

Right to receive personal data in structured, machine-readable format

Right to transmit data to another data fiduciary

Right to direct transfer where technically feasible

Applies to consent-based and contractual processing

Does not affect rights of other individuals

Data Portability Process:

Submit request with specific data requirements

Identity verification and authentication

Data extraction in commonly used formats (CSV, JSON, PDF)

Secure transmission or download options

Technical support for data migration

 

8.5 Right to Nominate

Nomination Rights:

Right to nominate a person to exercise rights on your behalf

Applies in case of death or incapacity

Nominated person can exercise all data principal rights

Nomination can be updated or revoked at any time

Legal documentation required for nomination

Nomination Process:

Written nomination with nominated person’s consent

Identity verification for both parties

Legal documentation of incapacity (where applicable)

Registration of nomination in our systems

 

Notification and communication procedures

 

9. CONSENT MANAGEMENT

9.1 Consent Requirements

Valid Consent Characteristics:

Free: Given without coercion or deception

Informed: Based on clear and comprehensive information

Specific: Limited to specified purposes and processing activities

Clear: Unambiguous indication of data principal’s wishes

Withdrawable: Can be withdrawn as easily as it was given

Consent Documentation:

Record Keeping: Maintain records of when, how, and for what consent was obtained

Audit Trail: Complete history of consent changes and updates

Proof of Consent: Ability to demonstrate valid consent was obtained

Consent Receipts: Confirmation and documentation provided to data principals

Regular Review: Periodic assessment of consent validity and currency

 

9.2 Consent Collection Methods

Digital Consent Mechanisms:

Opt-in Checkboxes: Clear, unticked boxes requiring active consent

Granular Options: Separate consent for different processing purposes

Layered Notices: Brief summary with option to view detailed policy

Just-in-Time Consent: Consent requested when data is actually needed

Progressive Consent: Consent collected at relevant stages of customer journey

Offline Consent Procedures:

Written Forms: Physical consent forms with clear language

Verbal Consent: Recorded verbal consent with documentation

Representative Consent: Authorized person acting on behalf of data principal

Implied Consent: Only where legally permissible and clearly communicated

Signature Verification: Authentication of physical consent documents

 

9.3 Consent Withdrawal

Withdrawal Rights:

Easy Withdrawal: Simple process without unreasonable barriers

Multiple Channels: Online, email, phone, or written withdrawal options

Immediate Effect: Withdrawal takes effect immediately upon processing

Confirmation: Acknowledgment and confirmation of withdrawal

Impact Explanation: Clear information about consequences of withdrawal

Withdrawal Process:

  1. Request Submission: Submit withdrawal request through available channels
  2. Identity Verification: Verify identity to prevent unauthorized withdrawals
  3. Processing: Process withdrawal within 3-5 business days
  4. System Updates: Update all relevant systems and databases
  5. Third-Party Notification: Inform relevant third parties about withdrawal
  6. Confirmation: Send confirmation to data principal about withdrawal completion

 

9.4 Consent Management System

Technical Implementation:

Centralized Repository: Single source of truth for all consent records

Real-Time Updates: Immediate reflection of consent changes across systems

API Integration: Seamless integration with business applications

Automated Processing: Automated consent validation and enforcement

Reporting Dashboard: Real-time visibility into consent status and trends

Governance and Compliance:

Policy Alignment: Consent practices aligned with privacy policy and legal requirements

Regular Audits: Periodic review of consent management effectiveness

Staff Training: Training for staff on consent management procedures

Vendor Management: Ensuring third-party compliance with consent requirements

Continuous Improvement: Regular enhancement of consent management processes

 

10. COOKIES AND TRACKING TECHNOLOGIES

 

10.1 Types of Cookies Used

Essential Cookies (Always Active):

Session Management: User authentication and session security

Security Cookies: Protection against CSRF attacks and security threats

Load Balancing: Optimal server distribution and performance

Functional Cookies: Website functionality and user preferences

Accessibility: Support for users with disabilities and assistive technologies

Analytics Cookies (With Consent):

Google Analytics: Website traffic and user behavior analysis

Performance Monitoring: Page load times and error tracking

User Journey Mapping: Understanding customer interactions and pain points

Conversion Tracking: Measuring effectiveness of marketing campaigns

A/B Testing: Comparing different versions of web pages for optimization

Marketing Cookies (With Explicit Consent):

Advertising Cookies: Targeted advertising and remarketing campaigns

Social Media Integration: Sharing and interaction with social platforms

Personalization: Customized content and product recommendations

Campaign Attribution: Tracking marketing campaign effectiveness

Cross-Device Tracking: Linking user activities across multiple devices

 

10.2 Cookie Management

User Control Options:

Cookie Banner: Clear notification and consent mechanism on first visit

Granular Control: Option to accept/reject specific cookie categories

Cookie Settings: Dedicated page for managing cookie preferences

Browser Settings: Information about browser-level cookie controls

Regular Review: Periodic reminders about cookie settings and preferences

Technical Implementation:

Consent Recording: Documentation of cookie consent decisions

Dynamic Loading: Cookies loaded only after appropriate consent

Expiration Management: Automatic expiration and renewal of cookies

Cross-Domain Policies: Handling cookies across different domains

Mobile App Tracking: Similar controls for mobile application tracking

 

10.3 Third-Party Integrations

Google Services:

Google Analytics: Website analytics and reporting (with consent)

Google Ads: Advertising and remarketing campaigns (with consent)

Google Maps: Location services and branch finder functionality

reCAPTCHA: Spam protection and security verification

Google Fonts: Web font delivery and display optimization

Social Media Platforms:

Facebook Pixel: Social media advertising and tracking (with consent)

LinkedIn Insights: Professional network analytics (with consent)

Twitter Analytics: Social media engagement measurement (with consent)

YouTube Embedded Videos: Video content delivery and analytics

WhatsApp Business: Customer communication and support integration

Financial Service Integrations:

Payment Gateways: Secure payment processing and transaction management

Credit Bureau APIs: Credit score retrieval and verification

Banking APIs: Account verification and transaction processing

KYC Service Providers: Identity verification and compliance checking

Document Verification: Automated document authentication services

 

11. INTERNATIONAL DATA TRANSFERS

11.1 Data Localization Requirements

Indian Data Storage:

All personal data collected in India is primarily stored on servers located within India

Critical personal data and sensitive personal data stored exclusively in India

Compliance with RBI data localization guidelines for financial services

Use of Indian data centers certified for security and compliance standards

Regular audits of data location and storage practices

Cross-Border Processing:

Limited cross-border data transfers only when necessary for service delivery

Transfers to countries with adequate data protection frameworks

Contractual safeguards and standard contractual clauses for international transfers

 

Prior consent for cross-border transfers where required by law

Documentation and reporting of all international data transfers

 

11.2 Safeguards for International Transfers

Adequacy and Contractual Protections:

Adequacy Decisions: Transfers to countries recognized as providing adequate protection

Standard Contractual Clauses: Use of approved contractual clauses for data transfers

Binding Corporate Rules: Internal policies for multinational service providers

Codes of Conduct: Industry-specific codes for data protection compliance

Certification Mechanisms: Third-party certifications for data protection standards

Technical and Organizational Measures:

Encryption in Transit: All international data transfers encrypted using industry standards

Secure Transmission Protocols: Use of VPN, SFTP, and other secure channels

Access Controls: Restricted access to transferred data based on need-to-know

Audit Trails: Complete logging of international data access and processing

Data Minimization: Transfer only necessary data for specific purposes

 

11.3 Specific Transfer Scenarios

Technology Service Providers:

Cloud service providers with data centers in India and adequate security measures

Software vendors providing services under strict data processing agreements

Cybersecurity service providers for threat detection and incident response

Analytics platforms with data processing capabilities in approved jurisdictions

Backup and disaster recovery services with appropriate safeguards

Regulatory and Compliance Requirements:

Sharing with international regulatory bodies under mutual cooperation agreements

Cross-border investigations and legal proceedings with appropriate legal basis

International credit bureau reporting under established frameworks

Tax reporting and compliance obligations in multiple jurisdictions

Anti-money laundering and counter-terrorism cooperation with international authorities

 

12. CHILDREN’S PRIVACY

12.1 Age Restrictions and Verification

Minimum Age Requirements:

Our services are not intended for individuals under 18 years of age

Business loans require minimum age of 21 years (as per lending criteria)

Specific age verification procedures for loan applications

Parental consent requirements for processing data of minors (where applicable)

Additional protections for sensitive categories of personal data

Age Verification Procedures:

Government-issued ID verification for age confirmation

Cross-verification with official databases and records

Additional documentation requirements for young adults

Regular review of age verification procedures and accuracy

Training for staff on handling minor-related data requests

 

12.2 Special Protections for Minors

Enhanced Consent Mechanisms:

Parental Consent: Verifiable parental consent for data processing of minors

Guardian Authorization: Legal guardian approval for financial service applications

Simplified Language: Clear, age-appropriate privacy notices and consent forms

Limited Data Collection: Minimal data collection necessary for service provision

Enhanced Security: Additional security measures for minor-related data

Rights and Protections:

Enhanced Deletion Rights: Stronger right to erasure for data collected during minority

Parental Access: Parents’ right to access and control their child’s personal data

Regular Review: Periodic assessment of continued need for minor’s data

Educational Resources: Information about digital privacy and data protection

Safe Communication: Secure channels for minor-related communications and requests

 

13. GRIEVANCE REDRESSAL MECHANISM

13.1 Internal Grievance Process

Three-Tier Grievance Structure:

Level 1: First Point of Contact

Contact: Privacy Officer / Customer Service Team

Email: bankingserviceshub@gmail.com

Phone: (+91) 9758043094

Response Time: 3-5 business days

Resolution Time: 15 days from receipt of complaint

Level 2: Escalation to Management

Contact: Senior Management / Compliance Officer

Escalation Timeline: If not resolved within 15 days of Level 1

Response Time: 2-3 business days for acknowledgment

Resolution Time: 30 days from escalation

Level 3: Final Internal Review

Contact: Chief Executive / Board-Designated Officer

Escalation Timeline: If not resolved within 30 days of Level 2

Response Time: 1-2 business days for acknowledgment

Resolution Time: 45 days from final escalation

 

13.2 Complaint Filing Process

How to File a Privacy Complaint:

  1. Written Complaint: Email or letter detailing the privacy concern
  2. Identity Verification: Provide identification to authenticate the complaint
  3. Specific Details: Clear description of the privacy issue and desired resolution
  4. Supporting Documents: Any relevant evidence or documentation
  5. Contact Information: Current contact details for communication

Required Information:

Personal Details: Name, contact information, and customer ID (if applicable)

Nature of Complaint: Specific privacy right violation or concern

Timeline: When the incident occurred or was discovered

Impact: How the privacy issue has affected you

 

Desired Resolution: What remedy or action you are seeking

 

13.3 External Grievance Options

Regulatory Escalation:

Data Protection Board of India (DPBI): Primary regulatory authority for DPDP Act violations

Reserve Bank of India: For financial services-related privacy complaints

Consumer Forums: Consumer protection courts at district, state, and national levels

Cyber Crime Cells: For technology-related privacy violations and data breaches

Industry Ombudsman: Banking Ombudsman for financial services complaints

Contact Information for External Bodies:

DPBI Portal: [To be updated when operational]

RBI Customer Service: 14448 (Toll-free)

Consumer Helpline: 1915 (National Consumer Helpline)

Cyber Crime Portal: cybercrime.gov.in

Banking Ombudsman: As per relevant territorial jurisdiction

 

13.4 Grievance Tracking and Resolution

Complaint Management System:

Unique Ticket Number: Every complaint assigned a unique reference number

Status Tracking: Real-time status updates available to complainants

Communication Log: Complete record of all interactions and communications

Resolution Documentation: Detailed record of investigation and resolution steps

Follow-up Procedures: Post-resolution follow-up to ensure satisfaction

Quality Assurance:

Independent Review: Complaints reviewed by personnel not involved in original processing

Root Cause Analysis: Investigation of systemic issues and process improvements

Training and Development: Staff training based on complaint patterns and issues

Policy Updates: Privacy policy and procedure updates based on complaint learnings

Regular Reporting: Management reporting on complaint trends and resolution effectiveness

 

14. UPDATES AND AMENDMENTS

14.1 Policy Review and Updates

Regular Review Schedule:

Annual Review: Comprehensive policy review at least once per year

Regulatory Updates: Immediate updates for regulatory changes and new laws

Business Changes: Updates for new services, products, or business processes

Technology Updates: Changes for new technology implementations or upgrades

Incident-Based Updates: Updates following significant privacy incidents or complaints

Review Process:

Cross-Functional Review: Input from legal, compliance, technology, and business teams

Stakeholder Consultation: Internal stakeholder review and approval process

Legal Review: Legal counsel review for compliance and accuracy

Board Approval: Senior management or board approval for significant changes

Documentation: Complete documentation of changes and rationale

 

14.2 Notification of Changes

Customer Notification Methods:

Website Notice: Prominent notice on website homepage and privacy policy page

Email Notification: Direct email to customers for material changes

SMS Alert: Text message notification for significant policy updates

Mobile App Notification: Push notification through mobile applications

Physical Mail: Postal notification for customers without digital contact preferences

Notice Timeline:

Advance Notice: Minimum 30 days advance notice for material changes

Immediate Notice: Immediate notification for changes benefiting customer privacy

Emergency Changes: Immediate implementation for security or legal compliance changes

Effective Date: Clear indication of when changes become effective

Transition Period: Reasonable transition period for customers to review changes

 

14.3 Continued Use and Acceptance

Implied Acceptance:

Continued use of services after notice period constitutes acceptance of updated policy

Clear communication about acceptance mechanism and alternatives

 

Option to withdraw consent or terminate service relationship if disagreeing with changes

No penalty for service termination due to privacy policy disagreements

Reasonable alternatives for customers who cannot accept policy changes

Active Consent Requirements:

Material Changes: Active consent required for significant expansions of data use

New Purposes: Explicit consent for new purposes not covered in original consent

New Categories: Consent for processing new categories of sensitive personal data

New Recipients: Consent for sharing data with new categories of third parties

Cross-Border Transfers: Additional consent for new international data transfers

 

15. CONTACT INFORMATION

15.1 Privacy Officer Contact Details

Primary Privacy Contact:

Designation: Privacy Officer / Data Protection Officer

Company: Banking Hub Services

Email: bankingserviceshub@gmail.com

Phone: (+91) 9758043094

Address: Block C-14, Shop No., Cloth Market, Sanjay Place, Agra – 282002, Uttar Pradesh,

India

Business Hours: Monday to Friday: 10:00 AM to 6:00 PM, Saturday: 10:00 AM to 2:00 PM

Alternative Contact Methods:

Website Contact Form: Available on https://bankinghubservices.com

Customer Service: General customer service can assist with privacy queries

Postal Mail: Written complaints and requests accepted via registered post

In-Person: Visit our office during business hours with prior appointment

WhatsApp Business: [If available] for quick queries and support

 

15.2 Response Timeframes

Standard Response Times:

Email Queries: 2-3 business days for initial response

Phone Calls: Immediate response during business hours

Written Requests: 5-7 business days for acknowledgment

Complex Investigations: 15-30 days depending on complexity

 

Rights Requests: As specified in applicable law (typically 30 days)

Escalation Timeline:

Level 1 Response: 3-5 business days

Management Escalation: 7-10 business days

Final Resolution: 30-45 business days maximum

Regulatory Complaint: As per regulatory authority timelines

Emergency Issues: Immediate response for data breach or security concerns

 

15.3 Office Hours and Availability

Regular Business Hours:

Monday to Friday: 10:00 AM to 6:00 PM IST

Saturday: 10:00 AM to 2:00 PM IST

Sunday: Closed (Emergency email support available)

Public Holidays: Closed with emergency contact available

Emergency Contact Procedures:

Data Breach: Immediate notification via email with “URGENT – DATA BREACH” subject

Security Incidents: 24/7 emergency contact for critical security issues

Fraudulent Activity: Immediate reporting through dedicated fraud hotline

System Downtime: Technical support available through online channels

After-Hours Support: Email support with next business day response guarantee

 

16. REGULATORY COMPLIANCE AND LEGAL FRAMEWORK

16.1 Applicable Laws and Regulations

Primary Legislation:

Digital Personal Data Protection Act, 2023: Primary data protection law governing digital

personal data

Information Technology Act, 2000: General technology and cyber law framework

Information Technology Rules, 2011: Specific rules for sensitive personal data

Reserve Bank of India Act, 1934: Banking regulation and oversight framework

Prevention of Money Laundering Act, 2002: Anti-money laundering and KYC requirements

Financial Services Regulations:

RBI Master Directions on KYC: Know Your Customer and due diligence requirements

RBI Digital Lending Guidelines: Specific provisions for digital lending data privacy

 

Credit Information Companies Regulation Act, 2005: Credit information sharing

framework

Banking Regulation Act, 1949: General banking operations and customer protection

Consumer Protection Act, 2019: Consumer rights and grievance redressal mechanisms

 

16.2 Regulatory Reporting and Compliance

Data Protection Board of India (DPBI):

Registration: Registration as Data Fiduciary as required under DPDP Act

Breach Notification: Mandatory breach notification within 72 hours

Compliance Reporting: Regular compliance reports and audit submissions

Fee Payment: Payment of applicable fees and penalties

Cooperation: Full cooperation with DPBI investigations and inquiries

Reserve Bank of India (RBI):

Regulatory Returns: Submission of required regulatory returns and reports

Inspection Cooperation: Full cooperation with RBI inspections and examinations

Guideline Compliance: Adherence to all applicable RBI guidelines and circulars

Incident Reporting: Reporting of significant operational and security incidents

Customer Complaint Reporting: Regular reporting of customer complaints and resolutions

 

16.3 Industry Standards and Best Practices

International Standards:

ISO 27001: Information Security Management System certification

ISO 27701: Privacy Information Management System standard

SOC 2: Service Organization Control audit and compliance

PCI DSS: Payment Card Industry Data Security Standard (where applicable)

GDPR Adequacy: Alignment with European data protection standards for global clients

Industry Best Practices:

Privacy by Design: Integration of privacy considerations into all business processes

Data Minimization: Collection and processing only necessary data for stated purposes

Transparency: Clear and understandable privacy notices and communications

Accountability: Demonstrable compliance with data protection obligations

Continuous Improvement: Regular review and enhancement of privacy practices

 

17. SPECIAL SITUATIONS AND EXCEPTIONS

17.1 Emergency and Crisis Situations

Emergency Data Processing:

Life-Threatening Situations: Processing without consent to protect vital interests

Natural Disasters: Special processing for disaster response and recovery

Pandemic Response: Public health emergency data processing as required by authorities

Financial System Stability: Processing for systemic risk management and stability

National Security: Cooperation with national security and defense authorities

Documentation and Safeguards:

Legal Basis Documentation: Clear documentation of emergency processing legal basis

Minimal Processing: Processing limited to what is necessary for emergency response

Temporary Duration: Emergency processing limited in time and scope

Post-Emergency Review: Review and deletion of data after emergency situation ends

Transparency: Communication to affected individuals about emergency processing

 

17.2 Legal Proceedings and Law Enforcement

Court Orders and Legal Process:

Compliance Obligation: Mandatory compliance with valid court orders and legal process

Scope Limitation: Disclosure limited to what is specifically required by legal order

Legal Review: Legal counsel review of all law enforcement requests

Documentation: Complete documentation of legal process and response

Customer Notification: Notification to affected customers where legally permissible

Law Enforcement Cooperation:

Criminal Investigations: Cooperation with legitimate criminal investigations

Regulatory Investigations: Support for regulatory enforcement actions

Anti-Fraud Activities: Proactive cooperation in fraud prevention and investigation

Financial Crime Prevention: Support for anti-money laundering and terrorism financing

prevention

International Cooperation: Cooperation with international law enforcement under mutual

legal assistance treaties

 

17.3 Business Transitions and Corporate Changes

Mergers and Acquisitions:

Due Diligence: Privacy impact assessment during due diligence process

Data Transfer: Secure transfer of customer data to acquiring entity

Policy Alignment: Alignment of privacy policies and practices post-transaction

Customer Notification: Advance notification to customers about business changes

Consent Management: Management of customer consent during transition

Business Closure or Insolvency:

Data Protection: Continued protection of customer data during business closure

Secure Disposal: Secure deletion or transfer of data as required by law

Customer Notification: Advance notice to customers about business closure impact

Regulatory Notification: Notification to regulatory authorities about data handling

Legal Compliance: Compliance with insolvency and business closure legal requirements

 

18. INTERNATIONAL CUSTOMERS

18.1 Cross-Border Service Delivery

Foreign Nationals in India:

Same Protection Standards: Equal privacy protection for foreign nationals using our

services

Passport Verification: Special procedures for passport-based identity verification

Embassy Coordination: Coordination with embassies for document verification where

required

Currency and Documentation: Handling foreign currency income and international

documentation

Exit Procedures: Special procedures for customers leaving India permanently

Non-Resident Indians (NRIs):

NRI-Specific Services: Tailored loan products and services for NRI customers

International Documentation: Handling overseas income and employment verification

Currency Conversion: Foreign exchange and currency conversion data processing

Tax Compliance: International tax reporting and compliance obligations

Communication Channels: International communication and customer service options

 

18.2 Compliance with Foreign Laws

Conflict of Laws:

Hierarchy of Laws: Indian law takes precedence for operations in India

International Treaties: Compliance with applicable international agreements and treaties

Diplomatic Immunity: Special procedures for customers with diplomatic status

Sanctions Compliance: Adherence to international sanctions and embargo requirements

Reporting Obligations: International reporting obligations under tax and regulatory

frameworks

Customer Rights Under Foreign Laws:

Additional Rights: Recognition of additional privacy rights under customer’s home country

law

Consular Access: Cooperation with consular services for customer protection

Legal Representation: Right to legal representation under applicable laws

Translation Services: Translation of documents and communications where required

Cultural Sensitivity: Respect for cultural and religious considerations in data handling

 

CONCLUSION

Banking Hub Services is committed to protecting your privacy and personal information while

providing excellent loan facilitation services. This Privacy Policy reflects our dedication to

transparency, compliance with applicable laws, and respect for your privacy rights.

We continuously monitor and update our privacy practices to ensure they remain effective and

compliant with evolving legal requirements and industry best practices. Your trust is essential to

our business, and we are committed to earning and maintaining that trust through responsible

data handling and transparent communication.

If you have any questions, concerns, or feedback about this Privacy Policy or our privacy

practices, please do not hesitate to contact our Privacy Officer using the contact information

provided in this policy.

For immediate privacy concerns or data protection queries:

Email: bankingserviceshub@gmail.com

Phone: (+91) 9758043094

Address: Block C-14, Shop No., Cloth Market, Sanjay Place, Agra – 282002

Document Information:

Policy Version: 1.0

Effective Date: [Insert Date]

 

Last Updated: [Insert Date]

Next Review Date: [Insert Date + 1 Year]

Approved By: [Board/Management Approval]

Document Owner: Privacy Officer, Banking Hub Services

This Privacy Policy is available in English. For queries about translations or accessibility, please

contact our Privacy Officer.

END OF PRIVACY POLICY




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